Compliance, or non-compliance, are not abstract concepts; you are compliant or non-compliant in relation to the population of items in your business that are subject to controls, under whatever jurisdiction(s) apply.
It follows that the first, and in many ways the most important, step in establishing your compliance programme is a thorough, documented classification exercise. However daunting this may seem, building a compliance system without this groundwork is simply not possible.
Governments are not adequately resourced to provide large-scale classification support to companies and encourage self-classification for precisely this reason. A professionally conducted and documented classification exercise demonstrates due diligence by your business in establishing the foundation of an effective compliance programme and forms the basis for maximising the efficiency of that programme in the future.
If your company or your supply chain has been impacted by US export control reforms, much historic classification data in your business may now be incorrect, leading to confusion in the supply chain, possible programme delays and costs, as well as damaging credibility with your customers.
David Hayes Export Controls has provided jurisdiction and classification advice and support to many, diverse clients, under both UK and US regulations and covering both military and dual-use controls. In respect of dual-use controls, we have clients in each of the ten categories in the dual-use list, providing considerable breadth of practical experience across many industry sectors.
Even if your current situation means that nothing has been classified and the task therefore seems daunting, our background and experience mean that we can perform this work very reliably and cost effectively.
For export classification advice please contact us.